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Finland's Proposed ATAD-Compliant Interest Restriction Rules

02 October 2018

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Proposed Changes

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Finland

On 27 September 2018, the Finnish government announced its proposal for new interest deduction restriction rules that are compliant with the EU Anti-Tax Avoidance Directive. Key points of the rules are as follows: A general 25% of EBITDA interest deduction restriction will apply for both related and unrelated party debt; A EUR 500,000 safe harbor will apply for related party debt (current rule maintained) and a EUR 3 million safe harbor will apply for unrelated party debt (new rule); The definition of interest expense for the purpose of the rules will be expanded to include expenses incurred in connection with...